Value-Based Care Comes Full Circle: New CMS Guidance for Medicaid Programs

This fall, the Centers for Medicare & Medicaid Services (“CMS”) published new guidance on the implementation of value-based care (“VBC”) and payment models focused on the Medicaid Program.

Any provider who regularly cares for Medicaid beneficiaries will recognize that the Medicaid Program does not pay providers well — often not enough to even cover costs to furnish services to a given beneficiary. Alternative payment methodologies that offer upside must fund those opportunities from somewhere, but it is not clear from where a broad alternative payment methodology in the Medicaid would do so.

Value-based care and payment arrangements necessarily involve a lot of moving parts. Data must be collected, analyzed, and reported in a compliant manner, patients must be coordinated and assigned to specific providers to permit tracking, anomalies in patient care rhythms must be tracked and addressed, and at the end of the day someone must figure out who is owed what money — and why.